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5 Pressing Questions Surrounding Enterprise E-911 in 2022

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Image: Y H Lim - Alamy Stock Photo
Federal legislation (Kari’s Law and RAY BAUM’s Act) and their mutually inclusive regulations, including finding, routing, and reporting an E-911 emergency event, have phased into place over the last few years. The final requirements of the RAY BAUM’s Act, dispatchable location for non-fixed voice endpoints— just went live January 6, 2022.
 
You’ve heard the trumpets sound off about these requirements for several years now. If your organization has already put an Enterprise NG/E-911 (911) solution in place, excellent. Even so, further mitigation may be required to comply with the latest RAY BAUM’s Act requirements. If you are currently seeking a 911 solution for your organization, you’ll need to fast-track your road map and implementation plan to get one in place ASAP.
 
Organizations must have or seek out full competency of the requirements and strategies to mitigate any gaps in their existing voice network by investigating the legislation via an organization’s legal and enlisting accredited subject-matter-experts (SME).
 
Knowing the law is the first step, mitigating any voice communication gaps in compliance is the second. It is paramount to have a plan or roadmap for assessment, selection, and implementation of the enterprise 911 solution. And it is paramount to execute that plan in a timely fashion in order to become compliant with Federal Communications Commission (FCC) and state regulations. The roadmap and plan need to consider both the technology component and the organization’s policies/procedures surrounding E-911 emergency response and management.
 
With all this in mind, let’s answer five pressing questions regarding Enterprise NG/E-911 (911).
 
1. What is required compliance with Federal and State Enterprise E-911 legislation?
That depends. Currently 24 states have varying legislation in place. Certain states have more relaxed requirements for enterprise 911. While others can be interpreted to include stricter compliance measures than those of the FCC.
 
An organization especially, those with locations in multiple states will need to search out the advice of competent subject-matter-experts and their attorneys to roadmap its compliance with these laws.
 
2. What does “dispatchable location” mean? What other considerations are there other than be compliant with legislative requirements?
A dispatchable location is defined as, “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party (RAY BAUM’s Act, Section 506).” The dispatchable location needs to be quickly identifiable by first responders—and may include things like: vanity building names, floors, geographic quadrants, building/floor signage, meet-me-doors, and gurney-capable elevators. And location and additional situational awareness data need to be delivered in a format PSAPs can receive whether transported via a traditional E-911 network or an NG 911 ESInet conceptual design.
 
3. Am I correct that the latest 911 MLTS FCC regulations do not apply to on-premises PBX systems installed before 2019?
No—if the PBX system can produce required functions or features via reconfiguration or programming, the operator must modify the existing PBX to perform the function. Examples include direct access to 911 (dial access prefixes), onsite notification, and OPX/VPN remotely connected devices.
 
4. Is NG911 a requirement of Kari’s Law or Ray Baum’s Act? Does this have any bearing on the emergency services network moving from TDM to IP core? How could this affect Enterprise 911?
Both Kari’s Law and RAY BAUM’s act were enacted to produce a safer environment for all enterprise organizations utilizing either legacy TDM E-911 or IP-based NG911 networks for their emergency calling. All compliance requirements of the legislation can be met in TDM or IP networks. Even nomadic non-fixed voice endpoints can be tracked and dispatched with the utilization of third-party emergency services network riding “over-the-top” of an existing TDM E-911 network.
 
With that said, legacy TDM E-911 service networks and their inherently cumbersome voice end-point location database updating process, are being migrated by AT&T, Verizon, Lumen, and others to NG911 ESInet core networks utilizing real-time location updating during an IP call set-up. Legacy TDM networks typically require 24–48-hours to properly update voice end-point location database(s) update sequence. This process is totally insufficient when an enterprise is required to track non-fixed voice endpoints. Real-time location identification in an ESInet environment is best achieved for all voice devices. We bring this up here because when choosing an enterprise 911 solution platform, an organization must choose wisely to accommodate and integrate with both legacy TDM E-911 and NG911 ESInet public network cores.
 
5. Are the requirements of the FCC legislation optional for call center or contact center agents? Is this also required in a UCaaS, work-from-home environment (remote workers)?
Call center agents, regardless of their location—on-premises or off-campus in a remote office—require enhanced 911 calling capabilities. The agent must be able to call 911 in an emergency regardless of the voice endpoint (hard-phone, soft-phone, WebRTC, etc.), detailed geographic location, onsite notification, and proper call routing to the correct ECC is required by law (RAY BAUM’s Act).
 
This short Q&A list hits some of the major concerns for any enterprise wishing to comply with the most current E-911 FCC legislation, though we are only touching the tip of the iceberg. If you already have an E-911 platform, please assess its capabilities making sure that it is compliant with both Kari’s Law and RAY BAUM’s Act regulations.
 
You may have additional questions or need assistance in formulating an assessment. Whether it be gap analysis, a road map to compliance, or formulating an assessment, the team at Vita Safety Partners is here to help! Please contact us at [email protected].
 
Editor's Note: A previous version of this story included the wording "The dispatchable location needs to be quickly identifiable by first responders—and must include things like: vanity building names, floors, geographic quadrants, building/floor signage, meet-me-doors, and gurney-capable elevators." This has been updated to more accurately reflect the language of the legislation.


Bill is writing on behalf of the SCTC, a premier professional organization for independent consultants. SCTC consultant members are leaders in the industry, able to provide best of breed professional services in a wide array of technologies. Every consultant member commits annually to a strict Code of Ethics, ensuring they work for the client benefit only and do not receive financial compensation from vendors and service providers.

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